Draft 

Issue Resolution Matrix for SC&A Findings on the General Steel 

Industries Special Exposure Cohort (SEC) Petition-00105 and the 

NIOSH SEC Petition Evaluation Report 

S. Cohen & Associates 

1608 Spring Hill Road 

Suite 400 

Vienna, VA 22182 

Original Date: October 6, 2009 

NIOSH Responses: October 9, 2009 

SC&A Reply: October 12, 2009 

Updated: July 25, 2011 

Second Update: September 17, 2011 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
 INTRODUCTION

The present document presents an update of the issues arising from the SC&A review of the 

General Steel Industries (GSI) Special Exposure Cohort (SEC) Petition-00105 and the National 

Institute for Occupational Safety and Health (NIOSH) SEC Petition Evaluation Report. It is 

current as of the last meeting of the Advisory Board on Radiation and Worker Health (ABRWH) 

Work Group on TBD-6000 in Hebron, Kentucky, on October 12, 2010. A separate issues matrix 

pertaining to SC&A findings on Appendix BB to “Site Profiles for Atomic Weapons Employers 

that Worked Uranium and Thorium Metals” (Allen and Glover 2007) was originally issued on 

May 2, 2008.1 An update of the Appendix BB issues matrix, including the latest developments 

on those issues, is being distributed as a separate document simultaneously with the present 

matrix. Although the two SC&A reports that form the bases of these matrices have different 

objectives, there is considerable overlap between the two sets of issues and hence the two 

matrices. 

Time Line of SEC Issues Matrix

 February 25, 2008: NIOSH received SEC petition from redacted (2008) on behalf of 

herself and former GSI employees and their survivors. 

 May 15, 2008: Petition SEC-00105 qualified for “[a]ll individuals who worked in any 

location at the General Steel Industries site, located on 1417 State Street, Granite City, 

Illinois, from January 1, 1953 through December 31, 1966, and/or during the residual 

period from January 1, 1967 through December 31, 1992 (Buker et al. 2008).”2 

 October 3, 2008: NIOSH issued an SEC petition evaluation report (Buker et al. 2008). 

 July 24, 2009: SC&A (2009a) prepared a review of the SEC petition and the NIOSH 

evaluation report (ER) and submitted it for Department of Energy (DOE) review and 

approval. This report was distributed on August 7, 2009, following DOE approval. 

 October 2, 2009: SC&A distributed the SEC issues matrix which listed 10 issues. 

These issues were taken from the list of 10 findings3 presented in the executive 

summary of our review of the SEC petition and ER (SC&A 2009a). 

 October 9, 2009: NIOSH responded to the 10 issues, inserting its responses in the 

boxes labeled “NIOSH Response.” 

 October 12, 2009: SC&A replied to the NIOSH responses in a revised, restricted 

version of the SEC issues matrix. 

 1

 Three versions of the matrix were previously distributed to the ABRWH Work Group on TBD 

6000/6001: (1) the initial matrix on May 2, 2008, (2) NIOSH responses to the issues, distributed by NIOSH on June 

19, 2008, and (3) an edited version with the revision history on the cover, issued December 8, 2009. 

2

 Buker et al. (2008) amended the covered period as ending June 30, 1966, and the residual period as 

beginning July 1, 1966. 

3

 The “findings” in the earlier report are presented as “issues” in the present document. Several of these 

issues overlap those in the Appendix BB issues matrix. 

Draft SEC Petition Issues Matrix 2 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
 December 16, 2009: The Work Group on TBD 6000/6001, Appendix BB,4

 met in 

Hebron, Kentucky, and recommended action items to NIOSH regarding the SEC issues. 

 April 24, 2010: Paul Ziemer, Chair of ABRWH Work Group on TBD-6000, issued a 

memo summarizing the action items from the December 16, 2009, work group meeting 

(ABRWH 2010). We have summarized each action item pertaining to the SEC issues 

in the box labeled “Board Action.” 

 October 08, 2010: Allen (2010) prepared the “Path Forward for GSI Appendix and ER 

Review,” in which he presented the proposed NIOSH responses to several of the SEC 

issues. We have summarized these responses in boxes labeled “Path Forward” in the 

appropriate locations in the matrix. 

 October 12, 2010: The Work Group on TBD-6000 met in Hebron, Kentucky. The 

work group asked SC&A to update both the Appendix BB and the GSI SEC issues 

matrices to reflect work group recommendations and the NIOSH responses in the “Path 

Forward.” 

 July 23, 2011: SC&A updated the GSI SEC issues matrix, appending an observation or 

reply to each relevant issue in the appropriate location in the matrix. We also listed the 

current status of each issue. 

 August 10, 2011: Allen (2011) prepared “Battelle-TBD-6000 Appendix BB General 

Steel Industries: Dose Estimates for Portable Radiography Sources.” 

 September 15, 2011: Anigstein (2011) prepared “Review of NIOSH Report on 

Portable Radiography Sources at GSI—August 2011.” 

 September 17, 2011: SC&A updated the matrix, incorporating our review of Allen 

2011. 

Status Summary 

 Issues 1–3, 5, and 6 are Open, according to the work group. 

 Issue 4 (residual radiation from betatron): Responsibility assigned to NIOSH by the 

work group. Pending resolution by NIOSH, the issue should remain Open. 

 Issue 7 (scientific errors in Appendix BB to be addressed by NIOSH): The work group 

directed that the issue be closed when NIOSH corrects the errors. Until such a time, the 

issue is In Progress. 

 Issue 8 (incomplete model used for exposure assessments): NIOSH asserts that this is 

an Appendix BB issue. SC&A believes that this should remain an SEC issue until 

NIOSH demonstrates that it can reconstruct doses from all sources. Until such a time, 

the issue should remain Open. 

 4

 In March 2010, this work group was divided into two separate work groups—Advisory Board Work 

Group on TBD-6000 and Advisory Board Work Group on TBD-6001 

Draft SEC Petition Issues Matrix 3 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
 Issue 9 (underestimate of beta dose): This issue has two parts: (1) underestimate of 

dose rates due to neglect of Putzier Effect, and (2) failure to assign beta dose to workers 

such as chainmen who loaded and secured uranium ingots on rail cars inside the plant. 

The work group observed that the first part of the issue is being addressed as part of the 

TBD-6000 review. However, the review of the impact of the Putzier Effect on the dose 

estimates in TBD-6000 is based on the results in table 6.4. However, as noted by Allen 

and Glover (2007, Section BB.4), the dose rates for specific types of work in table 6.4 

of TBD-6000 do not apply to GSI. Thus, this issue will need to be addressed separately 

for GSI, at which time increases of both the beta and photon doses will need to be 

considered. The second part has not been addressed by NIOSH; until such a time, this 

part of the issue should remain Open. 

 Issue 10: Closed, according to the work group. 

Level of Importance

We have assigned two levels of importance to these issues, which we define in the following 

manner: 

 High: NIOSH has not demonstrated that it can calculate doses with sufficient 

accuracy. 

 Medium: NIOSH has not described the methods that it will employ to calculate doses 

with sufficient accuracy; however, such methods can most likely be developed. 

We have assigned the following levels of importance to these issues: 

 Issue 1, 3, and 6: High

 Issues 2, 4, 5, 7–9: Medium

 Issue 10 (closed): Level of importance irrelevant 

Draft SEC Petition Issues Matrix 4 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Draft SEC Petition Issues Matrix 5 SC&A – Updated September 17, 2011 

 All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 

NOTICE:

Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report 

Issue 1: Lack of Radiation Monitoring Data for 1953–1963 

SC&A Finding: The lack of radiation monitoring data for the 11-year period 1953–1963 precludes a 

bounding assessment of external exposures to direct penetrating radiation. There were four reported 

incidents during this period: (1) a worker who was not a radiographer mistakenly took home a 60Co 

source; 5 (2) [REDACTED], who was not a radiographer, remained inside an Army tank being 

radiographed with the betatron; (3) [Worker A], a betatron operator, reported he was involved in an 

incident with “Betatron II” (presumably the new betatron) just prior to the beginning of the Landauer film 

badge monitoring program; (4) an employee of St. Louis Testing, a GSI contractor, reported finding an 

unsecured 60Co source that may have exposed GSI employees. These incidents, especially the worker’s 

taking home a 60Co source, indicate a serious breakdown of radiation controls. 

NIOSH Response (10/9/09): The incidents mentioned are specific events from years ago based on 

recent memories of operators. This specific nature of the descriptions provided by the operators indicates 

that they have clear recollections of these events. This implies that these events were likely to be 

unusual occurrences, rather than an indication of systemic breakdown of radiological controls. 

Regardless, there has been little or no credit given to any radiological controls in the appendix or the ER 

in mitigating radiation exposures. 

As with all dose reconstructions, NIOSH accommodates known incidents into the individual dose 

reconstruction based on information specific to the case. One of the events described above has already 

been incorporated into an individual’s dose reconstruction. 

SC&A Reply (10/12/09): There were thousands of workers employed at GSI and its predecessor, 

General Steel Castings, during 1953–1963. To the best of our knowledge, approximately 40 former 

workers or their family members have participated in meetings or have been interviewed, a very small 

fraction of the total work force. There could have been numerous incidents that were unknown to or 

forgotten by these individuals from over 50 years ago. For instance, NIOSH would not be able account 

for an incident involving a deceased worker if the claimant were one of his children who might have been 

born after the incident occurred. 

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): Agreed to hold the issue of FB records and source terms open 

until NIOSH completes the evaluation of the new documents identified by the petitioner (Reference: 

p. 181 of the 12/[16]/09 transcript.) 

NIOSH Path Forward (10/08/10) (Allen 2010): SC&A pointed out that several incidents were verbalized 

by workers and without film badge data, other incidents could be unknown. The handling of incidents is 

discussed in the Co-60 section of the path forward [below]. A preliminary review indicates a consistent 

frequency through the years that monitoring data is available. 

GSI Co-60 sources (1962 on) 

 Develop worker exposure scenarios – both radiography room and open area radiography 

 Radiographers reported to wear film badges when working with isotopes 

 Divide film badge readings into normal and incident readings (assume over 100 mr in a week is 

an incident). Determine frequency and amount of incident exposures and distribution of 

remaining doses. 

 Reconcile “normal” film badge readings with radiographer exposure scenarios. 

 Add incident exposure based on frequency and amount of incidents

 5

 Based on more recent information, it now appears that the source consisted of 226Ra. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

SC&A Comment (7/23/11): The film badge reports furnished by Landauer list only two weekly readings 

>100 mrem during the covered period (i.e., up to June 30, 1966) (Anigstein 2009). It is not possible to 

construct a meaningful distribution based on these two readings. Allen (2010) might intend to include 

additional film badge records for the period July 1966 through December 1977, during which there were 

several more weekly readings >100 mrem. 

We do not believe that it is correct to extrapolate data from that period to the 1962–1963 period, because 

operating conditions were significantly different during the two periods. The Landauer film badge 

monitoring began in mid-November 1963. Since this date coincides with the installation of the new 

betatron (transferred from the closed GSI facility in Eddystone, Pennsylvania), exposure conditions were 

most likely different during the Landauer period. For instance, the expanded use of the betatrons might 

have led to a decrease in the use of sealed sources and thus a lower frequency of incidents. 

Status (9/17/11): Open 

Issue 2: Incomplete Monitoring of Workers: 1964–1966 

SC&A Finding: The film badge dosimetry records for 1964–1966 list the names of 89 workers, who are 

believed to have been members of the betatron teams or radiographers who used sealed sources. 

Former workers have reported that the badges were stored in a rack just outside the New Betatron 

Building, and that they were required to take off their badges whenever they left the betatron buildings. 

Consequently, the monitoring of even these workers was incomplete, since it did not cover exposures 

they might have received outside the betatron building. Areas in 10 Building, including the restroom, 

were potentially exposed while the betatron was in operation. Furthermore, some of these workers may 

have worked as layout men who were in intimate contact with castings immediately after betatron 

radiography. They would not have been wearing their badges while performing such duties. The 

monitored workers represent a small fraction of the total GSI workforce. One incident that occurred 

during this period involved a worker who was inside a casting while it was radiographed with a betatron. 

He was in the plant engineering department and was therefore not monitored.

NIOSH Response (10/9/09): While information has come to light that the radiographers took off their film 

badges when they left the Betatron building, testimony and affidavits indicate radiographers did wear their 

film badges when performing radiography outside the betatron buildings. The dose to layout men was 

modeled by SC&A in the Appendix BB review and found to be less than the dose to betatron operators. 

The dose to other areas outside the betatron building was addressed in the ER. NIOSH does 

acknowledge, however, that there was a misconception about when the practice of “flipping the betatron 

head” began. It appears it could have occurred as early as November 1965, leaving about 19 to 20 

months of covered period where this could be an issue. Operators have indicated this was not a frequent 

practice but it does require further analysis. 

SC&A Reply (10/12/09): We agree that the exposure of nonradiographers in proximity to the New 

Betatron Building in 1965–1966 needs to be studied further.

Board Action: (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): Similar to Issue 1; keep this issue open. (Reference: p. 184 of 

the 12/[16]/09 transcript.) 

NIOSH Path Forward (10/08/10) (Allen 2010): SC&A pointed out that betatron operators removed their 

badges when leaving the betatron building but scenarios exist where they could have been exposed 

outside that building. The path forward addresses developing new exposure scenarios based on all the 

information that has come to NIOSH since the appendix was approved.

Status (9/17/11): Open 

Draft SEC Petition Issues Matrix 6 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

Issue 3: Lack of Documentation 

SC&A Finding: There are few contemporary records to document operations at GSI during the 

operational period. The available records comprise purchase orders for uranium radiography spanning 

the period 1958–1963, correspondence between General Steel and Mallinckrodt regarding payment of a 

single invoice for radiography prior to February 1958, a December 1953 memo referring to betatron 

radiography at General Steel Castings (as GSI was then known), and Landauer film badge dosimetry 

reports for 1964–1973. There is no information on the extent of uranium radiography at GSI prior to 

March 1, 1958, except for a February 28, 1958, memo requesting payment for an earlier invoice 

(Brownfield 1958). Consequently, it does not appear to be possible to determine the exposure of workers 

to uranium from January 1, 1953, the assumed start of uranium handling operations, to March 1, 1958. 

There are no records regarding the radioactive sources used for radiography. For example, the “small” 60Co source used in 6 Building was variously described as having an activity of less than one curie or 

0.25 Ci. The large source was described as 80 Ci; however, we could not determine when it was 

acquired. Given the 5.27 half-life of this nuclide, the date of acquisition would affect its activity at various 

times during the operation of GSI. Given the paucity of documentation, it is difficult to establish suitable 

parameters for dose reconstruction. 

NIOSH Response (10/9/09): The first part of the issue indicates there is no indication of the extent of 

uranium radiography prior to 1958. However, the SC&A review of appendix BB estimated that 

radiography operations of steel produced higher doses to operators than operations with uranium. It 

therefore appears to be a favorable assumption to assume no uranium work occurred prior to 1958. 

The only record of the use or the existence of these sources is that of worker testimony. The 

radiographer testimony also indicated they wore their film badges when using these sources. 

SC&A Reply (10/12/09): The question remains: Is it possible to perform dose reconstructions with 

“sufficient accuracy” in the absence of documentation on sources of radiation?

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): Keep this issue open pending review of the new documents. 

(Reference: p. 196 of the 12/[16]/09 transcript.) 

NIOSH Path Forward (10/08/10) (Allen 2010): SC&A indicated that the amount of uranium work is 

unknown prior to 1958 and that there is no record of the type of radiography sources used at GSI. The 

path forward addresses developing new exposure scenarios based on all the information that has come 

to NIOSH since the appendix was approved. This includes information about the radiography sources 

used at GSI.

NIOSH Report on Portable Sources (8/11/11) (Allen 2011): Allen (2011) identified the two 500-mCi 226Ra sources used at GSI prior to May 1962, and the two “small” 60Co sources (260 mCi and 280 mCi) 

procured at that time, as well as the 10-Ci 60Co source and the 50-Ci 192Ir source used at GSI by St. Louis 

Testing. He also described the operating characteristics of the two 250 kVp x-ray machines used for 

radiographing steel castings and derived their output. Allen estimated the exposures of radiographers 

and of other workers to the 226Ra sources, based on safety practices that he assumed were used in later 

years and which he projected backwards to the “radium era” (prior to May 1962). He cited the results of a 

radiation protection survey of the radiography room performed after the procurement of the “small” 60Co 

sources, and used the highest exposure rates in a potentially occupied area to estimate the annual 

exposures of GSI workers, including both radiographers and nonradiographers. He also estimated the 

exposures of GSI employees to the St. Louis Testing sources. 

SC&A Review of NIOSH Report (9/15/11) (Anigstein 2011): We have confirmed the information about 

the characteristics of the portable radiography sources used at GSI during the period of AEC operations 

presented by Allen (2011). We found that the fundamental assumption regarding the safety practices 

employed by GSI during the use of 226Ra sources during the radium era was based on a misinterpretation 

of information furnished by a former worker and then projected backwards to an earlier time period. 

Absent any information about the whereabouts of the radiographer and other workers during the 

Draft SEC Petition Issues Matrix 7 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

employment of the 226Ra sources, absent any radiation monitoring data, and absent any evidence of an 

effective radiation safety program during this time, we do not believe there is a sufficient basis for 

estimating worker exposures during this time period. A glaring failure of radiation safety is evidenced by 

the unauthorized removal of a 226Ra source from the premises. 

We do not agree with Allen’s method of assigning bounding doses to GSI workers during the post-radium 

era. We have proposed a modification of Allen’s exposure scenario to the St. Louis Testing sources, 

which results in a slightly higher exposure of radiographers (due to their intrusion into the exclusion 

boundary during the temporary absence of St. Louis Testing personnel), and in over twice the exposure 

to nonradiographers, whom Allen assumes are exposed for only one-half their workday. However, we 

believe that these are tractable problems which can be resolved. 

Status (9/17/11): Open 

Issue 4: Film Badge Dosimetry Dependence on Photon Energies and Exposure Geometry 

SC&A Finding: The response of a film badge dosimeter is highly dependent on the angle of the incident 

radiation, especially if the radiation source is behind a person wearing a film badge on the front of his 

body. To a smaller extent, the film badge response varies with the energy of the incident photons. 

Consequently, given the complex exposure conditions at GSI, the film badge records are at best an 

approximate measure of the radiation doses received by their wearers. 

NIOSH Response (10/9/09): The film badges response is relatively uniform for energies beyond a few 

hundred keV. They tend to over respond to energies below that. The angle of incident radiation is not an 

issue specific to GSI, it is an issue that has been discussed [in] a number of other settings. In general, an 

assumed AP geometry is favorable for most organs. However, if the dose on a film badge is assumed to 

be caused by a PA exposure, it can be accounted for using ICRP or NCRP standards. 

SC&A Reply (10/12/09): The issue here is that corrections for the attenuation of incident radiation in the 

PA orientation when the badge is worn in front are dependent on photon energy. Since the energy 

spectrum of the residual radiation from the betatron apparatus is unknown, it would be difficult to correct 

for the exposure geometry.

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): SC&A to provide an analysis relating to this issue. (Reference: 

p. 231 of the 12/[16/]09 transcript.) 

SC&A Analysis (5/9/10): We performed an analysis of the betatron apparatus and its electrical circuitry 

to develop three possible exposure scenarios. We then calculated the radiation exposure from the most 

probable of these three scenarios. We could not find a physical explanation for the residual exposure 

rate reported by Schuetz (2007). Absent an understanding of the mechanism by which the reported 

residual radiation was generated, we cannot determine the quality of the radiation (i.e., the photon energy 

spectrum). Thus, the underresponse of the workers’ film badges to radiation incident in the 

posteroanterior (PA) orientation cannot be quantified. (SC&A 2010) 

Board Action (5/12/10): Discussed at meeting of the Work Group on TBD-6000. According to Paul 

Ziemer, chair of the work group, “In part, the burden will be on NIOSH again to figure out what do we do 

with this information.” 

Status (9/17/11): Open 

Issue 5: Lack of Validation of Models of Radiation Exposure of Betatron Operators 

SC&A Finding: Even for the period of time for which film badge dosimetry reports are available, there is 

no agreement between the measured and the modeled exposures. In SC&A 2008, we have presented a 

detailed critique of the models of external exposure developed by Allen and Glover (2007). We have 

performed an independent analysis to demonstrate that the exposures to betatron radiation and to 

activated steel could be higher than those predicted by the NIOSH model. However, we do not claim that 

our model is definitive, based as it is on a limited set of exposure scenarios and extensive conjectures on 

Draft SEC Petition Issues Matrix 8 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

exposure durations and geometries. 

The film badge data indicate that the vast majority of weekly reports list doses of less than the reporting 

level of 10 mrem. These results call both the NIOSH and SC&A models into question. Conversely, 

neither model explains how one worker received a dose of 2,470 mrem in one week during the period of 

covered operations, or how another worker was reported to have received a dose of 7,590 mrem in one 

week after the end of AEC operations at GSI. Although the latter dose is, strictly speaking, outside the 

scope of this review, it does call into question the exposure conditions at GSI. Since there is no basis for 

believing that the operating conditions were significantly different in the later years, except for the 

absence of uranium, such a dose report should be considered in evaluating the models of external 

exposure. 

In short, neither the film badge data nor the modeled exposures can be used to establish an upper bound 

to the external exposures of betatron operators that is claimant favorable and scientifically correct.

NIOSH Response (10/9/09): Appendix BB attempted to be a bounding estimate. In a number of places 

in the SC&A review of that Appendix, there is indication of the modeled dose being conservative. Both 

imply that if successful, real data such as the film badge data should be lower. That appears to be the 

case. 

The few reported high doses could be indicative of an incident or as some workers reported, dropping 

their badge in the shooting room or intentionally putting someone else’s badge in the shooting room. A 

NIOSH white paper presented to the WG analyzed the film badge data which included some of these 

values. In that manner, it is assumed they are related to real incident exposures and the dose as well as 

the likelihood of an incident are accounted for. 

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): Keep this issue open pending analysis of the new documents. 

(Reference: p. 250 of the 12/[16]/09 transcript.) 

NIOSH Path Forward (10/08/10) (Allen 2010): SC&A indicated there is no agreement between the 

appendix model and the film badge results. The path forward addresses developing new exposure 

models and reconciling them with the film badge data.

Status (9/17/11): Open 

Issue 6: Underestimate of External Exposure of Unmonitored Workers 

SC&A Finding: Allen and Glover (2007) make a seemingly arbitrary distinction between two classes of 

workers. Betatron operators and workers who handle metal within 2 hours of irradiation are assigned a 

higher exposure, ranging from 2.1 to 6.3 R/y, depending on the calendar year, while all other workers are 

assigned a dose of about 1.7 R/y. The latter exposure rate is based on a calculated exposure rate of 

0.72 mR/h in shielded areas of the plant. SC&A (2008) has calculated exposure rates far in excess of 

this value in locations accessible to workers not involved in radiography, including a rate in excess of 

1 R/h on the roof while the 80 Ci 60Co source was in use. Given the lack of any systematic program of 

radiation protection to bar access to these areas during betatron or 60Co radiography, and the fact that the 

exposures of these other workers were not monitored, it does not appear to be possible to bound their 

radiation exposures in a manner that is scientifically correct and claimant favorable. Thus, the distinction 

between the external exposures assigned to these two classes of workers is not adequately justified and 

could result in a significant underestimate of the external exposures of some of the workers that are 

assigned the lower exposures. 

NIOSH Response (10/9/09): Two models were developed to provide a distinction between plant 

personnel and office personnel and others clearly not routinely exposed. The 2 hour cut-off was based 

on the method used to develop that model and provides the dose reconstructor with some guidelines 

when reviewing an individual case. Most are assigned the radiographer dose in dose reconstruction. 

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Draft SEC Petition Issues Matrix 9 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

Action items (4/24/10) (ABRWH 2010): Keep this issue open pending analysis of the new documents. 

(Reference: p. 263 of the 12/[16]/09 transcript.) 

NIOSH Path Forward (10/08/10) (Allen 2010): SC&A points out again that there are other exposure 

scenarios not addressed in the appendix. The path forward addresses developing new exposure 

scenarios based on all the information that has come to NIOSH since the appendix was approved and 

using those scenarios to revise the dose estimates.

NIOSH Report on Portable Sources (8/11/11) (Allen 2011): Allen (2011) developed several new 

scenarios for deriving bounding estimates radiation exposures of nonradiographers. During the “radium 

era” (prior to May 1962), he assumed that such workers would remain at the boundary of the “safe area” 

roped off during radiography using 226Ra sources, where he estimated the exposure rate to be 0.89 mR/h, 

but would occasionally intrude into this area while the radiographer was away. For the later period, Allen 

assigned limiting exposures of 1.348 R/y to nonradiographers to two 60Co sources (260 mCi and 280 

mCi), based on the highest exposure rates measured during a 1962 radiation safety survey of the 

radiographic room in No. 6 Building (NRC 2009). Allen estimated the exposures of nonradiographers to 

sources used on the GSI site by St. Louis Testing to be 1.336 R/y. This was based on the assumption 

that they remained at the 2-mR/h boundary established by St. Louis Testing for one-half of their workhours during the time that radiography by St. Louis Testing was in progress, and that they prevented from 

crossing the boundary by the St. Louis Testing radiographers who were assumed to be continuously on 

duty.

SC&A Review of NIOSH Report (9/15/11) (Anigstein 2011): As we discussed under Issue 3 of this 

matrix, we do not believe that there is any basis for assuming that a “safe area” was roped off during 

radiography with 226Ra sources. Consequently, we do not believe that NIOSH has sufficient information 

to estimate the doses to nonradiographers (nor to radiographers) during the radium era. We found that 

the limiting exposure of nonradiographers to portable sources following the radium era to be from sources 

used by St. Louis Testing. We do not agree that the limiting exposures of nonradiographers should be 

based on their spending only one-half their time at the 2 mR/h periphery. Since St. Louis Testing only 

had one radiographer on duty at any time, working a 12-h shift, there were obviously times he left his 

post, so a GSI employee, especially a nonradiographer, could have crossed the boundary. We believe 

that a bounding scenario should assume that any GSI worker could been at the 2 mR/h periphery when 

the source was in use , and that once during his shift he could have crossed the area inside this 

perimeter. We estimate the bounding exposure to these sources to be 2.8 R/y to all GSI plant workers. 

Status (9/17/11): Open 

Issue 7: Dose Reconstructions Not Based on Best Available Science 

SC&A Finding: SC&A (2008) has documented a number of scientific errors in Appendix BB. Most 

notable is a 20-fold error in calculating the dose rate from irradiated uranium, which we found in the 

computer program files used by NIOSH. Although this error increases the dose rate and is therefore 

claimant favorable, it is not scientifically correct. The calculated values are therefore not acceptable for 

use in dose reconstructions. 

NIOSH Response (10/9/09): The comment appears to be discussing the accuracy of the dose estimate 

rather than the ability to estimate the dose. As such, it would be more appropriate to remove this from the 

SEC review matrix and add it to the Appendix BB review matrix. 

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): This is not an SEC issue. NIOSH is correcting the error. Action 

to be confirmed at next meeting and the issue will be closed. (Reference: p. 264 of the 12/[16]/09 

transcript.) 

NIOSH Path Forward (10/08/10) (Allen 2010): Determine dose rates from activation and fission products 

and add to natural activity of uranium metal.

Draft SEC Petition Issues Matrix 10 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

SC&A Reply (7/23/11): NIOSH has not yet reported a correction to the errors cited above.

Status (9/17/11): In Progress 

Issue 8: Incomplete Model Used for Exposure Assessments 

SC&A Finding: It would appear that the model used by NIOSH for the 208 dose reconstructions 

completed by October 3, 2008, the date of the ER, is incomplete. We base this conclusion first on the 

response by NIOSH to some findings in the “Issue Resolution Matrix for SC&A Findings on Appendix BB 

to TBD-600[0],” dated June 19, 2008. In response to Issue 10: “Errors in Calculating Dose Rates from 

Uranium,” NIOSH wrote: 

To the extent modeled doses are used, any errors in this calculation will be corrected. 

However NIOSH has obtained film badge results for betatron operators. We are in the 

process of comparing this data to the modeled estimates provided by both the appendix 

and SC&A. 

Our review of Case [B] indicates that NIOSH did use doses modeled by Allen and Glover (2007). To the 

best of our knowledge, NIOSH has not revised this model. NIOSH made similar comments in response to

other SC&A findings regarding the scientific validity of the Appendix BB models. 

Other indications that the NIOSH model is incomplete are given by Buker et al. (2008). In section 7.3.4.1, 

under the heading “Neutron Dose,” is the statement, “A study is in place to determine the photon-toneutron ratio.” As we found in our audit of Case [B], NIOSH has neglected the neutron dose in 

performing dose reconstructions. 

Given the undetermined status of the model, we find that the dose reconstructions performed by NIOSH 

to date do not meet the standard of scientific accuracy.

NIOSH Response (10/9/09): The comment appears to be discussing the accuracy of the dose estimate 

rather than the ability to estimate the dose. As such, it would be more appropriate to remove this from the 

SEC review matrix and add it to the Appendix BB review matrix. 

SC&A Reply (7/23/11): We believe that this should remain an SEC issue until NIOSH demonstrates that 

it can calculate external doses with sufficient accuracy. One issue cited above is the neglect of neutron 

doses. Allen (2010) states that NIOSH will include neutron exposures in its revised model. However, 

NIOSH has not described any approach to calculating neutron doses other than one cited by NIOSH 

(2008), which proposed to use a neutron:photon ratio, based on SC&A’s calculations of betatron doses 

and exposures, scaled to photon doses taken from the Landauer film badge dosimetry reports. We 

continue to object to such an approach for several reasons. 

First, SC&A did not attempt to model the typical worker exposures over the course of a year. The 

purpose of our analyses of the 25-MeV betatron was to demonstrate that under a limited set of exposure 

conditions, the hourly dose rates in various locations were significantly higher than those calculated by 

NIOSH. Although we then extrapolated the hourly dose rates to estimate annual exposures and 

contrasted these with the annual exposures/doses presented by Allen and Glover (2007), we do not claim 

that our estimates correspond to average exposure conditions, nor that they represent a plausible upper 

bound. To do either would have required us to perform much more extensive analyses which would have 

exceeded our authorized scope of work. 

Our second objection to the NIOSH approach is to the manner in which NIOSH (2008) calculated the 

neutron:photon ratio. They used our estimated annual neutron dose, which was the dose to a betatron 

operator in the control room from neutrons emitted from the betatron target during radiography of a steel 

casting. They then calculated a ratio using our estimated annual photon exposure of the betaron operator 

from all sources, notwithstanding that 80% of this exposure was from the reported (Schuetz 2007) but 

unexplained radiation from the betatron after the beam was shut off. The fact that the average film badge 

dosimetry reports indicated lower photon doses than we estimated, based on our MCNP model of the 

betatron and the reported residual radiation from the betatron, does not justify decreasing the neutron 

doses by the same proportion. 

Draft SEC Petition Issues Matrix 11 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

Status (9/17/11): Open

Board Action: 

Issue 9: Underestimate of Beta Dose 

SC&A Finding: The beta dose assigned to GSI workers may be underestimated. Freshly cast uranium 

ingots may have enhanced concentrations of the short-lived progeny of 238U on the surface, leading to a 

significant increase in the beta dose over aged natural uranium metal. Furthermore, uranium ingots were 

handled not only by the betatron workers but also by chainmen who transferred the ingots from the trucks 

or railway cars on which they arrived at the plant to the plant’s own railway system. Such workers would 

also have been exposed to the beta rays from the uranium, but they are not assigned such exposures in 

the guidance for dose reconstruction of Allen and Glover (2007).

NIOSH Response (10/9/09): The comment appears to be discussing the accuracy of the dose estimate 

rather than the ability to estimate the dose. This issue has been raised in the Battelle-TBD-6000 review 

and appears on that issues matrix. Any revisions [to] Battelle-TBD-6000 will also result in revisions to 

applicable appendices. 

SC&A Reply (10/12/09): The NIOSH response does not address the workers who may have handled 

uranium on its way into and out of the betatron facilities but were not assigned the dose to radiographers 

and consequently were not assigned any skin dose.

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): This issue is being addressed under the TBD-6000 issues matrix 

(relating to the [Putzier] Effect). SC&A will provide a write-up withdrawing their comment (e.g., the 

[Putzier] Effect is really not involved in this situation). (References: pp. 266–268 of the 12/[16]/09 

transcript.) 

SC&A Response (5/9/10): As stated above, this issue has two components: 

1. Underestimate of skin dose to betatron operators due to neglect of the Putzier Effect. 

2. Failure to account for the skin dose to chainmen and other workers who handled uranium but who 

were not categorized as “betatron operators” (i.e., they did not operate the betatron nor did they handle 

metal within 2 hours of irradiation). 

As stated by Robert Anigstein (SC&A) at the May 12, 2010, work group meeting, we believe that the 

Putzier Effect is relevant to GSI, since there was most likely some recasting of ingots at Mallinckrodt and 

Weldon Spring, some of which may have been sent to GSI. We agree with the NIOSH response that the 

first part of issue 9 is also being addressed in the SC&A review of TBD-6000. We also agree with NIOSH 

that this part of issue 9 concerns the accuracy of the reconstruction of doses to the skin, rather than the 

ability to reconstruct the doses. However, we used the context of the SEC petition issues matrix to bring 

it to the attention of the Board because NIOSH has not addressed this and other dose reconstruction 

issues in the 2 years since the issuance of the original SC&A review of Appendix BB. 

NIOSH did not respond to item 2, above. To address this issue, NIOSH needs to expand the category of 

workers who receive doses to the skin from contact with uranium metal to include all workers who may 

have handled uranium before or after betatron irradiation, regardless of the time elapsed after irradiation. 

In the case of employees for whom precise job descriptions are not available, this could result in 

assigning doses to the skin to all employees who worked in the plant, with the likely exception of office or 

administrative personnel. Until we know how NIOSH will address this concern, we cannot judge if it is 

feasible to reconstruct doses to the skin of such workers. (SC&A 2010) 

Draft SEC Petition Issues Matrix 12 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Issue Resolution Matrix for SC&A Findings on the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report

(continued)

Draft SEC Petition Issues Matrix 13 SC&A – Updated September 17, 2011 

 All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 

NOTICE:

SC&A Observation (7/23/11): Allen (2009) indicated that although TBD-6000 did not explicitly 

incorporate the Putzier Effect in its dose estimates, comparisons of the derived 95th percentiles of deep 

and shallow doses6

 with maximum annual doses recorded at Fernald indicate that these estimates are 

claimant favorable. SC&A (2009b) concurred. However, it is not clear if these generic dose estimates will

be applied to exposures from uranium handling at GSI. Allen and Glover (2007, Section BB.4) stated, 

“Since this estimate relies on estimates of exposure times and dose rates, the dose rates for specific 

types of work in table 6.4 [TBD-6000] do not apply.” They consequently base their dose estimates on the 

dose rates from a rectangular uranium ingot, listed in table 6.1 of TBD-6000. We have two issues with 

that procedure: (1) the Putzier Effect is not included, and (2) the doses are from bremsstrahlung x rays 

and ignore the significant contribution of gamma radiation and the smaller contribution of characteristic 

x rays. That said, issue 2 is moot in terms of the doses from the uranium shapes handled at GSI, since 

the calculated doses from the rectangular ingot are twice the doses from the cylindrical ingot listed in 

table 6.1, and are larger still than the dose rates from a uranium slice calculated by SC&A (2008).7 Thus, 

the neglect of the gamma and x-ray doses is fortuitously compensated for by the claimant-favorable 

choice of the rectangular ingot. 

Status (9/17/11): Open 

Issue 10: Lack of Consistency in Assigning External Exposures 

SC&A Finding: Because of an error in calculating the external exposure to irradiated uranium, Allen and 

Glover (2007) assign a disproportionately high exposure rate to workers handling uranium following 

radiography while underestimating (in modeling terms) exposures to the betatron and to irradiated steel. 

This results in exposure rates that vary from year to year. By contrast, SC&A (2008) estimated that the 

bounding external exposures to direct penetrating radiation did not vary significantly over the duration of 

AEC operations. The dose reconstruction approach prescribed by NIOSH can inappropriately assign a 

dose to a betatron operator working in 1961 that would be 3 times the dose to one working in 1965.

NIOSH Response (10/9/09): The comment appears to be discussing the accuracy of the dose estimate 

rather than the ability to estimate the dose. As such, it would be more appropriate to remove this from the 

SEC review matrix and add it to the Appendix BB review matrix. 

Board Action (12/16/09): Discussed at meeting of the Work Group on TBD-6000/6001. 

Action items (4/24/10) (ABRWH 2010): Agreed to close the issue here and deal with it in the 

Appendix BB Issues Matrix. 

Status (9/17/11): Closed

 6

 It is not clear if “deep dose” corresponds to personal dose equivalent, Hp(10), or ambient dose equivalent 

H*(10)—organ DCFs based on both these quantities are listed in OCAS-IG-001. 

7

 Information furnished by former GSI workers after the preparation of the SC&A (2008) report indicates 

that some cylindrical ingots were radiographed at GSI as well as the uranium slices cited by Westbrook and Bloom 

(2010) and previously confirmed by the workers. 
References

Advisory Board on Radiation and Worker Health, TBD-6000 Work Group (ABRWH) 2010. 

“Summary of Action Items and Issues from December 12 [sic], 2009 Meeting” [Note: Meeting 

was held on December 16, 2009] (MS Word metadata: Author Paul L. Ziemer, created 4/24/10.) 

Allen, D. (NIOSH/DCAS). 2009. “Battelle-TBD-6000 Issue 1 White Paper: Consideration of 

Recasting Increasing Progeny Concentration.” 

Allen, D. (NIOSH/DCAS), 2010. “Path Forward for GSI Appendix and ER Review” (October 

08, 2010). 

Allen, D., (NIOSH/DCAS), 2011. “Battelle-TBD-6000 Appendix BB General Steel Industries: 

Dose Estimates for Portable Radiography Sources.” 

Allen, D., and S. Glover, 2007. “Site Profiles for Atomic Weapons Employers that Worked 

Uranium and Thorium Metals - Appendix BB: General Steel Industries,” Battelle-TBD-6000, 

Appendix BB, Rev. 0. http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r0.pdf

Anigstein, R. (SC&A). 2009. “Review of Film Badge Dosimetry Reports for GSI.” 

Anigstein, R. (SC&A). 2011. “Review of NIOSH Report on Portable Radiography Sources at 

GSI—August 2011.” 

Brownfield, C. M., 1958. “General Steel Castings Corporation Invoice #M-216." Mallinckrodt 

Chemical Works internal memorandum to J. P. O’Haire (February 28, 1958). SRDB Ref ID: 

16356, p. 17. 

Buker, L., R. Clark, M. Domal, and J. Guido, 2008. “SEC Petition Evaluation Report Petition 

SEC-00105.” http://www.cdc.gov/niosh/ocas/pdfs/sec/gsi/gsier.pdf

Redacted. 2008. “SEC Petition.” Letter to OCAS/NIOSH with attachments. 

National Institute for Occupational Safety and Health (NIOSH). 2008. “White Paper for GSI 

Appendix BB Review.” (MS Word metadata: Author dka6 [David Allen], created 11/13/08.) 

Nuclear Regulatory Commission (U.S.) (NRC). 2009. “General Steel Industries Byproduct 

Materials License for Cobalt-60 Sealed Source (Budd Company Model 41706) not to exceed 

1 curie, w/handwritten notes.” ADAMS acquisition number ML093451452. 

S. Cohen & Associates (SC&A). 2008. “Review of ‘Site Profiles for Atomic Weapons 

Employers That Worked Uranium and Thorium Metals - Appendix BB: General Steel 

Industries,’ Battelle-TBD-6000, Appendix BB, Rev. 0.” 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scagsireview.pdf

S. Cohen & Associates (SC&A). 2009a. “Review of the General Steel Industries Special 

Exposure Cohort (SEC) Petition-00105 and the NIOSH SEC Petition Evaluation Report.” 

Draft SEC Petition Issues Matrix 14 SC&A – Updated September 17, 2011 

NOTICE: All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 
Draft SEC Petition Issues Matrix 15 SC&A – Updated September 17, 2011 

 All Privacy Act-protected information in this September 17, 2011, version has been redacted. 

Future versions of this matrix will require additional reviews for Privacy Act-protected information. 

NOTICE:

S. Cohen & Associates (SC&A). 2009b. “Review of NIOSH Issue 1 White Paper Dated 

December 10, 2009.” 

S. Cohen & Associates (SC&A) 2010. “Response to Action Items Related to GSI SEC Issues 

Matrix.” 

Schuetz, J. G., 2007. Letter report to Samuel Glover, NIOSH/OCAS, May 1, 2007. 

Westbrook, J. L., and C. W. Bloom, 2007. “Basis for Development of an Exposure Matrix for 

the Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, 

St. Louis, Missouri,” ORAUT-TKBS-0005, Rev. 03. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/mallink-r3.pdf